Quashing jurisdiction and interim protection: blanket no-coercive-step orders need brief reasons and cannot routinely stop investigation.

The power to quash criminal proceedings is an extraordinary jurisdiction to be exercised sparingly, especially where an FIR discloses a cognizable offence. Interim protection staying investigation or directing that no coercive steps be taken is justified only in exceptional cases, such as absence of a cognizable offence, abuse of process, or risk of miscarriage of justice, and the High Court must record brief reasons showing application of mind. A blanket restraint on coercive action, particularly without reasons and during an ongoing investigation, impermissibly interferes with the statutory investigative process. The accused should ordinarily seek anticipatory bail instead.

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Issues: Whether, during pendency of a quashing petition under Article 226 of the Constitution of India and Section 482 of the Code of Criminal Procedure, the High Court can grant a blanket order of stay of investigation or an order that no coercive steps shall be taken, and whether such interim protection can be granted without brief reasons.

Analysis: The power to quash criminal proceedings is an extraordinary power to be exercised sparingly and with circumspection, particularly where the FIR discloses a cognizable offence. The police have a statutory right and duty to investigate cognizable offences, and the courts ordinarily should not thwart such investigation or usurp the investigative sphere. Interim protection in the nature of stay of investigation or no coercive steps may be justified only in exceptional cases where the FIR discloses no cognizable offence, or continuation of proceedings would amount to abuse of process, or non-interference would result in miscarriage of justice. Even then, the High Court must record brief reasons showing application of mind. A blanket order restraining coercive action, especially without reasons and while investigation is in progress, impermissibly hampers the statutory investigation and is not to be granted routinely; an accused facing arrest must ordinarily be relegated to the remedy of anticipatory bail under Section 438 of the Code of Criminal Procedure.

Conclusion: A blanket interim order of no coercive steps was not justified and was liable to be quashed, while the High Court was directed to consider the quashing petition on its own merits in accordance with law.

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